https://www.taxtmi.com/caselaws?id=202545 Adjustment for notional interest on outstanding receivables from associated enterprises was held unsustainable because a continuing debit balance, by itself, is not an "international transaction" under s.92B unless it is shown to have a bearing on the assessee's profits, income, losses, or assets; no such impact was demonstrated. Further, delayed realization must be examined in light of the agreed commercial payment terms, not in isolation. Even if treated as an international transaction, the TPO's CUP analysis was legally flawed: LIBOR applies to lending/borrowing, not trade overdues, and comparables must be receivables (debtors), not loans. Absent internal/external CUP evidence of interest on similar overdues, the ALP adjustment was deleted and the appeal allowed. en-us Wed, 05 Jan 2011 00:00:00 +0530 Mon, 22 Dec 2025 14:56:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202545 Adjustment for notional interest on outstanding receivables from associated enterprises was held unsustainable because a continuing debit balance, by itself, is not an "international transaction" under s.92B unless it is shown to have a bearing on the assessee's profits, income, losses, or assets; no such impact was demonstrated. Further, delayed realization must be examined in light of the agreed commercial payment terms, not in isolation. Even if treated as an international transaction, the TPO's CUP analysis was legally flawed: LIBOR applies to lending/borrowing, not trade overdues, and comparables must be receivables (debtors), not loans. Absent internal/external CUP evidence of interest on similar overdues, the ALP adjustment was deleted and the appeal allowed. Case-Laws Income Tax Wed, 05 Jan 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202545